U.S. Supreme Court Clarifies Emergency Entrance Standard for Officers

In a unanimous opinion, the United States Supreme Court recently reaffirmed that an officer may enter a home without a warrant if they have an objectively reasonable basis for believing an occupant is seriously injured or imminently threatened with such injury. Case v. Montana, 607 U.S. ___ (2026).

Montana officers responded to petitioner’s home after his ex-girlfriend reported that he was threatening suicide and may have shot himself. After observing an empty handgun holster and what appeared to be a suicide note, officers entered the home. Petitioner appeared to brandish a weapon, so an officer shot him. Petitioner was ultimately charged with assaulting a police officer, but he moved to suppress all evidence obtained based on the warrantless entry into his home. The trial court denied the motion, finding the officers were responding legitimately to a perceived injury, and a jury subsequently found Petitioner guilty. On appeal, the Montana Supreme Court upheld the entry as lawful under a “community caretaker doctrine.” Under that doctrine, police can enter homes for welfare checks when objective, specific, and articulable facts would lead an experienced officer to suspect a person inside needed help or was in peril. The Montana Supreme Court also rejected Petitioner’s argument that police must have probable cause to believe the occupant needs emergency aid.

On appeal, the United States Supreme Court upheld the standard articulated in Brigham City v. Stuart, 547 U.S. 398, 400 (2006). In Brigham City, the Court held that officers may enter when they have an objectively reasonable basis to believe an occupant is seriously injured or imminently threatened with injury. Petitioner here asked the court to interpret Brigham City as requiring probable cause for entry. The Court declined to do so—partially because the probable cause standard stems from criminal law—and further held that the Montana Supreme Court erred when it applied a standard akin to reasonable suspicion. The Court noted that emergency-aid entries are not analyzed through the same lens as investigative activity. Courts should instead assess the reasonableness of an emergency-aid entry on its own terms. The Court further found that the officers had an objectively reasonable basis for believing entry was necessary to prevent petitioner from ending his life. The objective reasonableness of an officer’s conduct is evaluated by looking at the totality of the circumstances. The statements from Petitioner’s ex-girlfriend, along with visual evidence corroborating those statements, indicated that Petitioner was suicidal. Thus, the decision to enter the home was reasonable.

The United States Supreme Court reiterated that “[a]n officer may enter a home without a warrant if he has ‘an objectively reasonable basis for believing that an occupant is seriously injured or imminently threatened with such injury.’” Case, 607 U.S. ___, 146 S. Ct. 500, 509 (2026). More narrowly, the Court’s holding clearly shows that the probable cause standard does not apply in a non-investigatory setting.

Read the opinion here: https://www.supremecourt.gov/opinions/25pdf/24-624_b07d.pdf